Accessible documents policy
This accessibility statement applies to documents published by the Biometrics and Surveillance Camera Commissioner.
We have certain obligations under the Public Sector Bodies (Website and Mobile Applications) (No.2) Accessibility Regulations 2018 (the accessibility regulations) to ensure that the Portable Document Format (PDF) documents that are published on our behalf on GOV.UK are accessible and comply with Web Content Accessibility Guidelines version 2.1 AA standard where that level is available. This document explains how those obligations are met. It does not cover content published on GOV.UK in Hypertext Markup Language (HTML) format: the main GOV.UK accessibility statement covers that.
Using our documents
We publish PDF documents on the GOV.UK website for use by organisations who operate, install and manufacture surveillance cameras as well as for members of the public. These documents serve a number of purposes and are categorised according to their purpose.
They include:
- guidance and templates
- tools to aid compliance with the legislation the Commissioner regulates
- information relevant to the requirements in a more general context
- agreements with other bodies or organisations
- leaflets and other marketing materials
- reports by the Commissioner
We want as many people as possible to be able to use those documents. Therefore, when a document is produced, care is taken to:
- tag headings and other parts of the document properly, so screen readers can understand the page structure
- make sure ‘alt text’ is included alongside non-decorative images, so people who cannot see them understand what they are there for
- avoid using tables, except when presenting data or when the information cannot be succinctly presented in another way
- write in plain English in so far as the technical nature of the documents allows
How accessible our documents are
Documents published by us from June 2020 have been produced with accessibility in mind and will satisfy the criteria for accessibility of Adobe Acrobat PDF. Consequently, they should be accessible. However, some of our previously published documents are not fully accessible. For example, some of them may not be tagged up in a way that allows screen reader technologies to understand them properly, or they may not contain alt text entries for non-decorative images.
Documents published before 23 September 2018 (the date on which the Regulations came into effect) and which are not active as part of our day-to-day functions are exempt from the accessibility regulations. Such documents might include, but are not limited to, ones which have been used during the development of current documentation. Such documents are themselves not used as part our day-to-day functioning and are not considered active. Consequently, there are currently no plans to make them accessible.
However, if you need to access information in one of these document types, you can contact us and ask for an alternative format.
What to do if you cannot use one of our documents
If your specific accessibility needs are not met by the criteria laid out for Adobe Acrobat PDF accessibility checkers, and you require one of our documents in a different format from that published, you can request that by emailing [email protected]
We will consider the request and respond in 14 calendar days to let you know whether your requirements can be met and a date by which a suitable alternative version can be provided.
Reporting accessibility problems with one of our documents
We are always looking to improve the accessibility of our documents. If you find any problems not listed on this page or you think we are not meeting accessibility requirements, contact the Biometrics and Surveillance Camera Commissioner at [email protected], quoting ‘Accessibility issue identification’ as the subject of your communication.
Include in your email the title of the document, hyperlink to the document and the nature of the issue. The issue will be investigated and a response provided, describing any action taken to remedy it.
Enforcement procedure
The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you are not happy with how your complaint is dealt with, contact the Equality Advisory and Support Service (EASS).
Technical information about the accessibility of our documents
We are committed to making their documents accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018.
The documents we publish are not compliant with the Web Content Accessibility Guidelines version 2.1 AA standard. The non-accessible sections are listed below.
Non-accessible content
The content listed below is non-accessible for the following reasons.
Non-compliance with the accessibility regulations
Some of our documents may have diagrams or charts which do not have a text alternative, so the information in them is not available to people using a screen reader. This does not meet WCAG 2.1 success criterion 1.1.1 (non-text content).
We plan to add text alternatives for all diagrams and charts to active documents when they are next updated. When new documents are published, use of diagrams will meet accessibility standards.
Some of our documents also contain tables which may be constructed in such a way that they are not easily understandable by screen reader technologies. This also does not meet WCAG 2.1 success criterion 1.1.1 (non-text content).
Restructuring of all tables within active documents is planned when documents are updated. When new documents are published, use of tables will meet accessibility standards.
Disproportionate burden
The following represents circumstances where it is considered a disproportionate burden to ensure that the documents described meet the requirements of the accessibility regulations.
Certain documents published after 23 September 2018 which are not considered active documents. Inactive documents fall into the following categories:
- records of consultation exercises which have been used to inform the production of active documents
- replaced documents (such as standards, guidance, information or protocol documents), which have been updated and re-issued
- historical documents (such as newsletters, minutes of meetings, audit reports and annual reports, prior to the latest versions)
Currently, there are no plans to ensure that such documents meet the requirements of the accessibility regulations as they are not active our day-to-day functioning. However, accessible versions may be requested by emailing [email protected]
Content that is not within the scope of the accessibility regulations
Many of our active PDFs do not meet accessibility standards - for example, they may not be structured so they are accessible to a screen reader. This does not meet WCAG 2.1 success criterion 4.1.2 (name, role value).
We plan to fix these issues and replace these PDFs with accessible ones as and when tools are updated.
The accessibility regulations do not require us to fix PDFs or other documents published before 23 September 2018 if they are not essential to providing services and do not form part of our day-to-day functions.
Any new documents published by us will be in an accessible format.
How we plan to test the documents
We plan to test the website for compliance with the Web Content Accessibility Guidelines V2.1 level A and level AA, by December 2022 and these tests will be carried out internally.
We used the Website Accessibility Conformance Evaluation Methodology (WCAG-EM) approach to deciding on a sample of pages to test.
We will update the website after the testing is completed.
What we’re doing to improve accessibility
We have documents that are used by the surveillance camera community and which may not fully meet the requirements of the accessibility regulations.
There is a plan to update these documents to make them accessible, which we have committed to do by December 2022.